per npdes profile: missouri · commission (a board appointed by missouri’s governor). permitting...

Permitting for Environmental Results (PER)

NPDES Profile: Missouri

PROGRAM RESPONSIBILITY State of Missouri: NPDES authority for base program, general permitting, federal facilities, and pretreatment EPA Region 7: NPDES authority for biosolids

Program Integrity Profile This profile characterizes key components of the National Pollutant Discharge Elimination System (NPDES) program, including program administration and implementation, environmental outcomes, enforcement, and compliance. EPA considers profiles to be an initial screen of NPDES permitting, water quality, enforcement, and compliance programs based on self-evaluations by the States and a review of national data. EPA will use the profiles to identify program strengths and opportunities for enhancements. For more information, please contact Peter Goode, P.E., Chief, NPDES Permits and Engineering Section, Missouri Department of Natural Resources, at (573) 751-1300 or John Dunn, EPA Region 7, at (913) 551-7594.

Section I. Program Administration

1. Resources and Overall Program Management

The State of Missouri: The Missouri Department of Natural Resources (MDNR) administers the NPDES program (except biosolids) in the State of Missouri, which received authorization on October 30, 1974. EPA serves in an oversight role. EPA reviews a number of major NPDES permits every year, including permits associated with water bodies on the list of impaired water bodies prepared under Clean Water Act section 303(d).

MDNR has issued individual permits to 145 major facilities and 2,879 minor facilities. MDNR has issued general permits (including stormwater permits) to over 8,000 facilities. The pretreatment program covers 566 significant industrial users (SIUs). MDNR has issued permits to 432 concentrated animal feeding operations (CAFOs). MDNR also administers permits for the federal facilities located in the State.1

MDNR’s NPDES program has recently become a part of the newly formed Water Protection Program in the Water Protection and Soil Conservation Division. The Water Protection Program was formed by incorporating the Water Pollution Control Program and the Public Drinking Water Program into a single water protection program. The change is expected to improve internal and external communications. The Water Protection Program now consists of the Water Pollution Control Branch, the Public Drinking Water Branch, the Water Protection Financial Assistance Center, and the Fiscal Management Unit.

1 Sources: Pretreatment Compliance System (PCS), 9/31/04, and third Quarter 2004 CAFO Rule Implementation Report.

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MISSOURI Last Updated - 3/18/05

The Water Pollution Control Branch now includes the NPDES Permits and Engineering Section, the Watershed Protection Section, the Water Pollution Compliance and Enforcement Section, and the Water Quality Monitoring and Assessment Section. The Water Protection Financial Assistance Center includes the Clean Water and Drinking Water State Revolving Fund engineering staff. The Fiscal Management Unit includes the administrative functions of both of the previous programs.

The reorganization is part of a broad-based effort to make MDNR more customer-friendly to the general public and regulated entities across the State of Missouri. Because of increased interdisciplinary coordination between program elements, the reorganization should result in better evaluations of watershed efforts and the State’s overall source water protection.

Expenditures and staffing: MDNR spent approximately $4.4 million on NPDES permitting and permit related efforts in fiscal year (FY) 2003. This figure includes salaries, expenses, and equipment expenditures of regional permit and inspection and enforcement staff, laboratory staff conducting water quality assessments and sample analyses, and personnel of the Geological Survey and Resource Assessment Division involved in hydrogeologic studies in areas with permitted discharges. MDNR has over 50 full-time equivalents (FTEs) in various programs who devote time to NPDES activities, including permitting, inspections, compliance and enforcement, engineering, and administration.

Over the past few years, MDNR has suffered budget cuts in general revenue. According to MDNR, general revenues have been reduced by 70% over the past 3 years. These cuts have led to the loss of several positions and extended vacancies in others. Loss of personnel affects Missouri’s ability to keep pace with an expanding permitting effort.

EPA Region 7: Two Region 7 staff members are assigned as the leads for the Region 7’s oversight of Missouri’s NPDES program, one for permit issuance and the other for compliance and enforcement. EPA also has staff members who work on issues related to pretreatment, water quality standards, total maximum daily loads (TMDLs), permitting oversight, stormwater inspection and enforcement, and legal matters.

Region 7 administers the biosolids program in Missouri. MDNR incorporates federal biosolids requirements into State-issued permits, and requires annual reporting from all sludge generators.

2. State Program Assistance

Region 7 assists MDNR through technical assistance and support. EPA has provided technical support on biosolids reclamation in the Tri-State mining area near Joplin and in the Old Lead Belt in southeastern Missouri.

Because of the permit backlog in Missouri, Region 7 has hired permit writers to assist MDNR in drafting permits. EPA also routinely conducts pretreatment inspections and occasionally stormwater inspections and enforcement. Region 7 staff participate in the monthly meetings of the Water Quality Coordinating Committee, consisting of about 50 stakeholders, and offer advice as part of the Poultry Dialogue in southwestern Missouri.

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3. EPA Activities in Indian Country

Not applicable because there are no federally recognized Indian Tribes in Missouri.

4. Legal Authorities

EPA is conducting a comprehensive review of the State’s legal authorities. This review has not yet been completed. As a result, EPA is reserving this section of the profile; when the legal reviews are complete, EPA will update profiles to include the results of the reviews.

On July 11, 2000, the Ozark Chapter of the Sierra Club, through the Interdisciplinary Environmental Clinic at Washington University, filed a petition for withdrawal of Missouri’s NPDES program, alleging that MDNR did not allow third-party appeals to NPDES permits.

5. Public Participation

An evaluation of the State’s legal authorities regarding public participation will be included in the legal authority review. As noted above, the legal authority review section of this profile is reserved pending completion of the legal authority review.

The State of Missouri: The procedures for seeking public participation are contained in the State of Missouri’s rules, Title 10 of the Code of State Regulations (CSR) 20-6.020. These rules require public notification and specified periods for public comment before the terms and conditions of operating permits are finalized. Anyone may submit comments on a draft permit. Although the “public” is not defined in State rules, MDNR is required by rule to consider all comments submitted in a timely manner before taking final action on a permit application. Public meetings are held when there are several requests and significant public interest. MDNR responds to written comments by letter, and the permit is revised accordingly. If the changes to the permit are substantial, the permit is again made available for public comment. Anyone who comments in response to the public notice may appeal MDNR’s final actions to the Clean Water Commission (a board appointed by Missouri’s governor).

Permitting records are open to public review during normal business hours. Records on facilities that are undergoing litigation may be withheld from public review until the case is resolved.

The State of Missouri’s commitment to “openness in government” is stated in Section 610.011 of the Sunshine Law: “It is the public policy of this state that meetings, records, votes, actions, and deliberations of public governmental bodies be open to the public unless otherwise provided by the law. The law sets out the specific instances when a meeting, record, or vote may be closed, while stressing these exceptions are to be strictly interpreted to promote the public policy of openness.”

Public notices were formerly sent out to a large mailing list of interested parties, but in an effort to gain cost savings, the public notices are now Web-based. Applications for general permits are made available for public comment if required by 10 CSR 20-6.020(1)(C)2. Other general permit applications are not required to be made available for public comment, but citizens may request the status of the application.

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MDNR has effectively used its Web site to enhance public access to State rules, relevant documents, draft permits, and supporting documents. Draft permits are posted every 2 weeks and include fact sheets and water quality review sheets, which detail the wasteload allocations. General permits for airports, chemical manufacturing, fabricated structured metal manufacturing, foundries, limestone and rock quarries, lubricant manufacturing, petroleum storage greater than 50,000 gallons, and wood treaters are required to be placed on public notice prior to issuance to a new facility. All final general permits and permits issued after January 2002 are available on the Web site. Press releases and fact sheets on hot topics are also available. The link for NPDES permit information is http://www.dnr.state.mo.us/wpscd/wpcp/wp-index.html.

The public can access information about enforcement and compliance actions through the Envirofacts and ECHO Web-based databases. In addition, the public may attend and participate in the bimonthly meetings of the Clean Water Commission and the monthly Water Coordinating Committee Meetings where a myriad of water quality issues are discussed. MDNR also participates in regular meetings with the Home Builders Association, the American Council of Engineering Companies, and other business and municipal groups.

EPA Region 7: EPA Region 7 provides outreach to the public as needed. The Region often participates in public meetings or forums where there is interest in a water-related topic. The Region has hosted meetings to explain new regulations such as the Phase II stormwater regulations or the new requirements for cooling water intakes for power plants. Region 7 also provides technical assistance on biosolids and other topics. Copies of major permits and general permits issued by the State can be found on EPA’s Web site at http://www.epa.gov/npdes/permitdocuments.

6. Permit Issuance Management Strategy

The State of Missouri: The backlog of expired permits is a significant concern. Thirty-three percent of major permits in Missouri are expired. Ten major permits have been expired for more than 5 years, and one of these permits has been expired for more than 10 years, due in part to promulgation and then withdrawal of EPA pesticide guidelines. Twenty-seven major permits have been expired for more than 2 years. For individual minor permits, the current backlog is 32%.

This concern is being addressed by several changes to internal personnel assignments within MDNR. These changes will allow for additional time for the more experienced staff to work through the technical issues affecting the major facilities. Permit efficiency efforts will also allow staff to spend more time on the difficult permits.

EPA has hired permit writers to assist Missouri in addressing the backlog. In addition, EPA will provide technical assistance to MDNR on difficult permits. EPA is working with MDNR on a backlog strategy to reduce the number of expired permits. The strategy will be completed by the end of 2005.

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http://www.dnr.state.mo.us/wpscd/wpcp/wp-index.html

http://www.epa.gov/npdes/permitdocuments


Table 1: Percentage of Facilities Covered by Current Permits in Missouri (State-Issued Permits)

2000 Nat’l Avg.

2001 Nat’l Avg.

2002 Nat’l Avg.

2003 Nat’l Avg.

Major Facilities 76% 74% 67% 76% 64% 83% 67% 84%

Minor Facilities Covered by Individual Permits

69% 69% 70% 73% 79% 79% 77% 81%

Minor Facilities Covered by Individual or Non-Stormwater General Permits

N/A N/A 66% 85% 69% 86%

Source: PCS, 12/31/00; 12/31/01; 12/31/02; 12/31/03. (The values in the National Data Sources column of the Management Report, measures #19 and #20, are PCS data as of 6/30/04.)

7. Data Management

The State of Missouri: Missouri uses its own State-developed mainframe-based system, which resides at the State Data Center. The State system is called the Water Quality Information System (WQIS). MDNR transmits data twice a week from WQIS to the Permits Compliance System (PCS), the federal NPDES database. MDNR receives edits and audit reports from PCS, and then uses these reports to ensure that PCS was correctly updated. Due to difficulties in updating issuance and expiration dates when data is transferred from WQIS to PCS, a significant number of records in PCS have blank issuance and expiration dates. (These records appear as “pending applications” on the Management Report, measure #18.) Missouri is working to resolve this issue. Missouri’s data entry rates for discharge monitoring reports (DMRs) during the quarter 7/1/03–9/30/03 were 85.6% for municipal facilities, 76.7% for nonmunicipal facilities, and 83% overall, which were below the national average for that quarter.2 However, this rate varies over time. For example, for the period beginning 1 month earlier than that shown on the Management Report, the entry rates were 93.6% for municipals, 87.8% for nonmunicipals, and 92% overall. MDNR enters data for most Water Enforcement Database (WENDB) data elements.

WQIS allows online inquiries (no password required), updating (password required), searching by facility name, and quick keys for moving around in the database. It is accessed through the State Data Center. Standard programs and tailored reports are frequently written for Freedom of Information Act requests. Many reports, form letters, and labels are printed for the management of day-to-day permit and program activities.

WQIS is a relational database application program with several COBOL processes performed in the background. WQIS can be broken into seven broad, logically distinct categories:

2 The National Data Sources column of the Management Report, measure #17, shows a DMR entry rate of 82%, based on a PCS retrieval on 6/28/04. Some of the missing DMR forms have been entered since that time, and a retrieval on 2/7/05 showed 83%.

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C general facility information (point and nonpoint source)

C permit limits

C enforcement and inspection data

C water quality monitoring and assessment data

C grant information

C facility monitoring data

C permit fees

There are also special data fields to flag certain types of permits such as CAFOs and municipalities with pretreatment programs. In most cases, the system uses a facility ID (typically the permit number) and outfall number to store a record in the database. Watersheds and sectors are managed using Hydrologic Unit Codes and water body numbers. Every classified water body in Missouri has a designated water body number, and every regulated facility on that water body is identified and tagged with that water body number.

The State of Missouri collects latitude and longitude data for NPDES facilities at the pipe level. Data for all site-specific and general permits are collected by field staff using hand-held GPS units and validated by the Water Quality Section using ArcInfo. All permit latitude and longitude data are validated at the time of permit reissuance using ArcInfo.

Missouri will transition from WQIS to the ICIS-NPDES (modernized PCS) system and begin downloading data from ICIS-NPDES for in-house use. The final decision on this transition is dependent on the final analysis of a contractor hired by the State to determine whether ICIS-NPDES will meet MDNR’s needs. In addition, a gap analysis is needed to determine the extent of programming that will be required to accomplish this goal.

EPA Region 7: Region 7 uses PCS to track basic permit and compliance information for major and minor facilities, including permittees with combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs), stormwater, CAFOs, pretreatment, and biosolids. Region 7 uses ICIS to track information drawn from Inspection and Case Conclusion Data Sheets, verify enforcement data, and record tips and complaints. OTIS and Envirofacts pull data from PCS to update each database.

Quarterly noncompliance reports (QNCRs) are retrieved from PCS searches for major facilities in significant noncompliance (SNC), as well as the enforcement actions being taken to address the facilities in SNC. Region 7 also checks how long facilities have been in SNC.

The Region enters all data elements of the Water Enforcement National Database (WENDB) for EPA-issued permits. The Region collects and enters audit reports into PCS to ensure that the data are accurately captured in PCS and that the data are entered as soon as they are received so that further processing can be completed.

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Section II. Program Implementation

1. Permit Quality

The State of Missouri: MDNR has moved to a computerized, paperless system for tracking applications, developing wasteload allocations, and drafting and issuing public notice permits. This minimizes unnecessary delays in the permit issuance process. The use of standardized forms and checklists has also improved permit quality and consistency. MDNR does not use the EPA Headquarters “central tenets” as a checklist for permit development.

MDNR has transferred some additional permit review responsibilities to its regional offices. Applications for most types of discharges are filed with the regional offices. The MDNR regional offices perform the reviews, post draft permits for public comment, respond to comments, and issue the permits. The MDNR central office is now responsible for permits for most major facilities, Class IA CAFOs, and a few general permits requiring coordination with other programs.

MDNR conducts water quality reviews in anticipation of applications for permit renewals. The water quality reviews provide information on the receiving water body, and specify any needed reductions in loadings from the facilities within the watershed. Having this information early in the permit renewal process allows staff to announce needed changes in discharges before the application review begins. It is hoped that discussions with applicants will promote the finalization of permit renewals before the current permits expire. The water quality review sheets supplement fact sheets and detail the wasteload allocation calculations used in permit development. Fact sheets have improved greatly over the past few years.

The MDNR has struggled with retention of staff. Experienced staff members are retiring and budget cuts preclude the backfilling of some of these positions. When individuals are hired, the State of Missouri’s low wage scale makes staff retention difficult. Many permit writers depart around the time when they become fully trained. There is a core of experienced permit writers, but it is small for the size of Missouri’s permit workload.

MDNR has placed limits for acute whole effluent toxicity (WET) in all major permits. Permits that have been on the backlog for a long time could have inadequate WET requirements. Catching up on the backlog is an important part of bringing WET limits up to date with State of Missouri standards. The MDNR standards include numeric standards for acute and chronic toxicity, but MDNR has not been willing to put chronic WET limits into NPDES permits. Permit limits for WET are expressed as a limit not to be exceeded. Permits indicate that exceedance of the limit is a permit violation, as well as a trigger requiring additional monitoring and follow-up.

EPA Region 7: Region 7 reviews a number of major permits each year as they are made available for public comment. Most reviews are an evaluation of calculations of permit limits for key pollutants of concern. In annual program reviews, a number of permits might be reviewed in a more complete way for procedural and technical content. As part of a consent agreement, 10 or more permits are reviewed each year to ensure

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that permits issued to facilities that discharge to impaired water bodies meet the requirements of TMDLs that have been issued.

2. Pretreatment

The State of Missouri: MDNR received authorization from EPA to implement the pretreatment program on June 3, 1981. Currently, 42 publicly owned treatment works (POTW) pretreatment programs are approved, and 3 are under development. Virtually all significant industrial users (SIUs) discharging to POTWs with approved pretreatment programs have active permits issued by their control authority. The POTW pretreatment programs typically issue permits following the EPA model permit. In addition, the State of Missouri directly oversees about 40 industries that discharge to POTWs without approved programs.

MDNR receives annual reports in March from the cities that have pretreatment programs, reviews them for compliance, and sends copies to Region 7. Through these annual reports, SIUs with control mechanisms are identified. MDNR identifies SIUs through several means, including direct contacts from SIUs, information supplied by POTWs, NPDES applications, on-site investigations, and information provided by citizens.

EPA Region 7: There are 44 pretreatment program cities, and 3 programs are under development in the State of Missouri. Two of these facilities are on “inactive status,” changing the number of active programs to 42. In addition, three cities are developing programs. Because MDNR is authorized to administer the pretreatment program once it approves the new programs, it will incorporate implementation language in the cities’ NPDES permits. Region 7 actively participates in audits of pretreatment cities and inspections of industrial facilities in the State of Missouri.

Region 7 issues an administrative order as a control mechanism for an SIU discharging to a POTW without a pretreatment program. For the roughly 40 SIUs outside pretreatment program cities in the State of Missouri, Region 7 has issued 7 administrative orders.

3. Concentrated Animal Feeding Operations

The State of Missouri: MDNR has very good (98%) NPDES permit coverage for Missouri’s CAFOs, with 432 of the estimated 439 CAFOs covered by NPDES permits.3 A general permit covers 408 operations and individual permits cover an additional 24 CAFOs. MDNR requires CAFOs with over 7,000 animal units to obtain individual permits, and MDNR inspects them quarterly.

Overall, MDNR will only need to make a few modifications to its CAFO regulations to fully implement EPA’s revised CAFO rule. Changes include adjusting some of the threshold numbers and adding phosphorus requirements to the present nitrogen land application requirements. MDNR held a stakeholder meeting in October 2004 to discuss a draft regulation and its plans for revising its CAFO program. MDNR has furnished a schedule to Region 7, which calls for completing the regulatory

3 The National Data Sources column on the Management Report, measure #11, shows an estimated 443 CAFOs. This estimate is based on information as of March 2004. The estimate of 439 CAFOs is based on information as of September 2004.

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process by May 2005.4 MDNR plans to formally establish State technical standards for nutrient management as part of its permits, rather than including the standards in its regulations.

4. Stormwater

The State of Missouri: MDNR has general Phase II construction permits in place and has issued a general permit to cover all Phase II municipal separate storm sewer systems (MS4s). Many industrial facilities are covered by general permits; others have site specific permits. MDNR completed issuing permits to all Phase I MS4s in 2004.5

Although MDNR has issued general permits for Phase II construction activities disturbing 1 acre or more, the administrative burden of processing permit applications, and enforcement of the permit requirements, is very high because the number of permits issued by MDNR has grown explosively. MDNR has developed “over the counter” permits for land disturbance activities that impact 1 to 5 acres to address part of the administrative burden. MDNR is also considering increasing the use of “permits-by-rule” to lessen administrative burdens.

5. Combined Sewer Overflows/Sanitary Sewer Overflows

The State of Missouri: MDNR has eight combined sewer systems. Three of the eight combined sewer systems have NPDES permits that require them to submit long-term control plans (LTCPs), and one of the combined systems is required by an abatement order to submit an LTCP. Submissions of these four LTCPs are required, but they have not yet been approved by MDNR. In addition, one of the eight combined sewer systems is being separated under a State consent judgment. Two of the combined systems need to develop LTCPs. MDNR is reissuing the NPDES permit for the remaining combined system, which will include the requirement to develop an LTCP or separate system. Overall, Missouri has begun to address all the remaining CSOs through permit conditions or through signed consent judgments.

Permittees are required to report CSOs and SSOs to the MDNR regional offices. Public notification is required electronically and in writing when a CSO is “not routine” and considered to pose a public health problem. Personnel from the MDNR regional offices investigate and, if any CSO/SSO violations are found, may write notices of violation; however, for significant violations MDNR proceeds with an appropriate enforcement action, which can include penalties and a compliance schedule. CSO communities have enforceable mechanisms to implement the nine minimum controls, including public notice either by permit or enforceable compliance order. MDNR views SSOs as any overflows that occur at permitted and unpermitted facilities. When overflows are reported, they are prioritized and investigated as potential violations. MDNR considers the discharges to be SNC discharges. In FY2005, MDNR is committed to develop an inventory of medium/large SSO communities in accordance with the

4 The National Data Sources column on the Management Report, measure #15, shows that completion of CAFO legal authority revisions was expected in November 2004. This was based on information as of March 2004. The schedule in place as of September 2004 provides for completion of the process by May 2005.

5 The National Data Sources column of the Management Report, measure #29, shows two Phase I stormwater permits as not yet issued. At the time the national data were gathered, in June 2004, the Kansas City and Independence permits had not been issued. These permits have since been issued – the Independence permit (MO0130401) on August 20, 2004, and the Kansas City permit (MO0130516) on September 3, 2004.

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EPA Office of Enforcement and Compliance Assurance (OECA) Enforcement Goals, and prioritize those SSO communities.

Although there are no regulations requiring capacity, management, operation, and maintenance (CMOM) programs, a few larger cities have collection system operation and maintenance programs similar to the CMOM plan requirements. EPA is working to identify training and outreach opportunities as well as incentives to implement CMOM within EPA Region 7.

6. Biosolids

The State of Missouri: MDNR does not have authorization to administer the NPDES biosolids program, and is not seeking authorization. MDNR has legal authority to administer a parallel biosolids program. MDNR’s biosolids standards are contained in the MDNR rules at 10 CSR 20-6.015, 7.015, 8.020, and 8.170. Subsection 7.015(9)(G) incorporates the federal standards from title 40 of the Code of Federal Regulations part 503 into State rule by reference. Despite the authority granted by these rules, MDNR has no funding mechanism to fully administer this portion of the program. MDNR incorporates standard biosolids handling requirements into each NPDES permit, including basic requirements such as monitoring for metals content, management plans, and record keeping.

EPA Region 7: Region 7 performs compliance assessment and enforcement. MDNR considers biosolids issues when inspecting municipal treatment plants and reports concerns to EPA for follow-up actions.

Almost all facilities in the State of Missouri apply their treated biosolids to land as an agricultural fertilizer. Several facilities in the Kansas City, Missouri, metropolitan area and two of the St. Louis Metropolitan Sewer District facilities in St. Louis, Missouri, incinerate biosolids. These large municipal facilities burn nearly half of the biosolids tonnage produced in the State of Missouri.

EPA reviews the annual reports of Missouri facilities and follows up on issues of concern. MDNR and EPA maintain coordination on various issues. EPA has provided technical assistance to MDNR in the beneficial use of biosolids for land reclamation in the Tri-State Mining Area near Joplin and in the Old Lead Belt of southeastern Missouri.

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Section III. NPDES Compliance Monitoring and Enforcement Response

In a separate initiative, EPA’s Office of Enforcement and Compliance Assurance (OECA), EPA Regions, and the Environmental Council of the States have developed a tool for assessing State performance in enforcement and compliance assurance to ensure that States meet agreed-upon minimum performance levels and provide a consistent level of environmental and public health protection nationwide. OECA will use the State profiles to focus these efforts and identify areas needing further discussion and evaluation.

1. Enforcement Program

The State of Missouri: MDNR’s inspection and enforcement manuals communicate the policies, procedures, guidelines, and expectations for the inspection and enforcement activities in each program. MDNR follows these policies and procedures so that due process can be demonstrated, a timely response can be ensured, and the problems are addressed to bring all facilities into compliance in a consistent manner. The inspection and enforcement manuals provide the basis for the programs and the regional offices to apply these tools in a consistent and effective manner.

MDNR uses an informal enforcement process called conference, conciliation, and persuasion (CC&P) to bring facilities into compliance. This is normally the first step used in the resolution of a violation. MDNR negotiates in good faith with the alleged violator to eliminate the alleged violation, and attempts to return the facility to compliance. The CC&P process cannot exceed 90 days without contacting the appropriate program to determine whether compliance can be reached. If compliance cannot be reached, enforcement action is warranted. Completion of the CC&P process should not exceed 180 days. If more time is needed, a written compliance schedule is negotiated. If CC&P fails to return a facility to compliance, the central office of MDNR moves to enforcement. The types of administrative actions that are issued by MDNR include notices of noncompliance, abatement orders with and without penalties, permit denials, and settlement agreements. MDNR also includes schedules of compliance in abatement orders, which contain specific timelines for achieving compliance. MDNR also refers enforcement actions to the Missouri Attorney General’s Office. In any case, several legal actions can be sought through the courts, such as recovery actions for damages and costs, injunctive relief, penalties, contempt citations, and imprisonment.

MDNR conducts scheduled inspections and file reviews of non-major facilities to promote proper operation of wastewater treatment facilities. MDNR also uses the facility’s monthly and quarterly discharge monitoring reports to determine compliance. Quarterly noncompliance reports (QNCRs) are sent to EPA Region 7. MDNR also conducts monthly reviews of facilities with significant and continual violations that cause them to appear on the QNCR, and MDNR follows up with any corrective or enforcement action, or both, on facilities identified as having violations.

MDNR has agreed in its current Performance Partnership Grant (PPG) to inspect 40% of major facilities and 20% of minor facilities annually. MDNR also inspects all Class IA CAFOs four times a year. MDNR reviews files and DMRs and assesses facility type, size, and the compliance history in order to target inspections. MDNR also focuses inspection and enforcement resources on sensitive areas in order

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to target the largest sources of potential water contaminants with the greatest potential to affect both public health and the environment.

MDNR has struggled with the responsibilities associated with the current federal stormwater program. The Phase II stormwater regulations, which require permitting of land disturbances of 1 acre or more, have created a huge number of new permitted sites. In FY2003, EPA conducted 19 stormwater inspections at construction sites in the State of Missouri. In FY 2003 EPA issued 10 administrative penalty orders and 7 administrative compliance orders. MDNR and EPA will continue to work collaboratively on inspection and enforcement through the State’s negotiated work plan agreement and quarterly meetings.

The following table reflects the previous 3 years of enforcement effort by MDNR to compel responsible parties to bring their facility or site into compliance and the amount of civil penalties and investigative costs and damages collected.

Table 2: Summary of Enforcement Actions State Fiscal Year, July 1 to June 30 2001 2002 2003 Inspections Conducted 1945 2059 2112 Complaint Investigations 1520 1714 1662 Notice of Violation Issued 540 563 N/A Enforcement Action Requests 72 81 58 Cases Resolved and Brought into Compliance 68 74 69 Abatement Orders Issued 8 8 5 Settlement Agreements Reached 37 59 24 Cases Referred to Attorney General 14 27 3 Investigative Costs and Damages Collected N/A $61,736.09 $95,300.5 Civil Penalties Collected $516,870.00 $442,729.68 $284,250.00

Source: Data provided by MDNR.

MDNR’s CAFO general permit covers 408 facilities; individual permits cover an additional 24 facilities. MDNR conducted 102 CAFO inspections in FY2003: 13 were for Class IB operations, 84 for Class IC operations, 4 for Class II operations, and 1 for a nonpermitted operation. MDNR inspects larger Class IA operations (the ones with individual permits) quarterly. MDNR also inspects all Class I CAFOs four times a year. The other general permittees are inspected randomly. MDNR’s goal is to inspect each CAFO at least once during the permit term. In addition, MDNR investigates all CAFO complaints and targets CAFO operations that are known to cause problems. A smaller animal feeding operation that poses water quality problems is required to obtain a permit until the problem is resolved.

MDNR views an SSO to any overflow from sanitary sewer collection systems. When overflows are reported, they are prioritized and investigated as potential violations. MDNR considers those discharges

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as SNC discharges. When SSO violations are identified, MDNR proceeds with whatever corrective actions are necessary to reach compliance.

All combined sewer systems have enforceable mechanisms to require implementation of the nine minimum controls through either permit conditions or an enforceable compliance order.

For FY2005, EPA is working with MDNR to develop an inventory of medium/large SSO communities in accordance with the OECA Enforcement Goals, and prioritize those SSO communities.

EPA Region 7: Region 7’s NPDES enforcement program includes approximately seven staff positions devoted to NPDES enforcement and one staff position devoted to data entry into PCS. This includes staff involved with inspection targeting; review and evaluation of inspection reports; oversight of enforcement programs; enforcement orders; State program assistance; responding to citizen complaints; oversight of enforcement program; enforcement case development; negotiation of enforcement cases; and tracking and evaluation of supplemental environmental projects schedules, and deliverables required by orders.

The Region formally targets inspections to investigate facilities that have the greatest potential for noncompliance. The Region also identifies noncompliant facilities according to national and regional priorities. Inspection reports are reviewed to determine whether an enforcement action is required. The Region has worked diligently and will continue to aggressively pursue appropriate enforcement actions against noncompliant facilities.

Region 7 uses the Interim Clean Water Act Settlement Penalty Policy to determine the penalties for violations in each enforcement action. EPA considers economic benefit and the ability to pay in determining penalties on a case-by-case basis.

The OECA regional trend data show a decrease in the number of new instances of facilities in SNC in the Region, an increase in the number of facilities addressed by formal enforcement actions, and an increase in the number of facilities that have returned to compliance on their own.

Table 3: SNC Status in Region 7

Year

Number of New SNC Facilities at the Beginning of the Year (7/1-6/30)

Percentage of SNC Facilities Addressed with Formal Enforcement Actions (10/1-9/30)

Percentage of SNC Facilities Returned to Compliance on Their Own (10/1-9/30)

Regional Total Regional Total Regional Total 2001 109 8% 78% 2002 108 10% 80% 2003 67 14% 82%

Based on the OECA trend data, major NPDES permittees in SNC at any time during the year in Region 7 have generally decreased from 123 in 2001 to 95 in 2002 to 67 in 2003. The Region will continue quarterly discussions with MDNR about noncompliant major facilities on both the QNCR and Watch List quarterly review, and encourage MDNR to continue the decrease in the number of facilities in SNC.

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2. Record Keeping and Reporting

The State of Missouri: MDNR’s Water Pollution Control Program has a standard procedure for enforcement file organization, including timely and accurate reporting and documentation supporting the alleged violations. All enforcement files are kept up-to-date and confidential, pending potential litigation. The MDNR inspection and enforcement manual contains specific guidelines for managing enforcement files.

EPA Region 7: Region 7 keeps up-to-date and accurate information on permittees for which the Region is responsible. Data for each permittee are stored in PCS and available in hard copy. The Region uses PCS to store basic facility information, address, outfall data, parameters and permit limits, DMR data, bypass and CSO reports, a summary of the schedule of compliance items, and completion dates. Hard copy files are divided into permit-related topics, inspections, DMRs, bypass/CSO reports, and other miscellaneous topics such as those related to requests and approvals for collection system extensions. Enforcement files contain necessary information to defend against subsequent appeals or court actions.

Region 7 uses PCS to manage its NPDES program. Region 7 inputs, directly into PCS, all of its enforcement actions, inspections, facility information, limits, outfall data, and permit issuance and expiration dates. Region 7 is confident that data quality will improve with the release of the new ICIS-NPDES (modernized PCS). The new system is much more functional than the current version of PCS. ICIS-NPDES will be more intuitive and have a modernized approach for entering NPDES data.

3. Inspections

The State of Missouri: Inspections are conducted to determine compliance with the Missouri Clean Water Law and its regulations and promote proper operation of wastewater treatment facilities. The intent of the program is to inspect 40% of major facilities annually. In 2003, MDNR inspected 34% of the major facilities and EPA inspected an additional 6% of major facilities. MDNR and EPA perform many inspections of minor facilities each year: 94% of MDNR inspections and 66% of EPA inspections in inspection year 2003 (7/1/02 – 6/30/03) were of minor facilities. All Class I CAFOs are inspected four times a year.

The statement of policy contained in the Missouri Clean Water Law, chapter 644.011, Revised Statutes of Missouri, clearly states that MDNR must protect the beneficial uses of waters of the State and meet Clean Water Act requirements. MDNR’s strategy focuses on the largest sources of potential water contaminants that have the greatest potential to impact both public health and the environment.

MDNR reviews all files before conducting inspections, including a facility’s DMRs. Factors determining the type and frequency of inspections and file reviews include the type of facility, the size of the population served, and the facility’s compliance history.

MDNR targets inspections based on facilities located in geologically sensitive areas.

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EPA Region 7: Region 7 uses numerous criteria when selecting targets for inspections such as a history of noncompliance, potential for environmental harm, citizen complaints, State requests, impaired water bodies, environmental justice concerns, watershed impacts, and Regional and national initiatives. Targets are selected to address and prevent environmental harm as well as in the priority wet weather core program areas. Wet weather has been a national priority for EPA in the past few years and Region 7 has focused inspections resources on meeting that priority.

The Region 7 targeting team shares the inspection list each year with the State and requests comments on it from the State.

Inspections of major facilities do not occur once every year because of the combined resource limitations faced by both Region 7 and its four States. Minor facilities might not be inspected every 5 years because of the same resource constraints.

4. Compliance Assistance

The State of Missouri:MDNR has an Environmental Assistance Office, which provides free assistance to municipal andnonmunicipal facilities, including operator training. It can be reached at 1-800-361-4827 or athttp://www.dnr.state.mo.us/oac/env_assistance.htm.

When permittees are in violation of their permits, MDNR uses the CC&P process, an informal enforcement process conducted between MDNR and the alleged violator. The purpose of the CC&P process is to appropriately resolve the violation through hands-on technical assistance and promptly return the facility to compliance. If CC&P fails to accomplish its goals, the case is referred to MDNR’s enforcement section for initiation of formal enforcement action.

MDNR also works closely with the University of Missouri as an outreach partner through the University Extension Office. Information on this outreach is available at http://outreach.missouri.edu/.

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http://www.dnr.state.mo.us/oac/env_assistance.htm

http://outreach.missouri.edu/


Section IV. Related Water Programs and Environmental Outcomes

1. Monitoring

The State of Missouri: Missouri does not have a monitoring program that satisfies all 10 elements outlined in EPA guidance. However, the State is making progress in writing a strategy for its monitoring program. The 2005 PPG with the State of Missouri requires that MDNR write a strategy for the monitoring program by the end of the fiscal year. The MDNR monitoring program might include the use of data from a statistical approach implemented by the Department of Conservation. It includes statewide annual monitoring. The monitoring program is not capable of providing background calculations for all NPDES permits in the State of Missouri, but it provides representative information that can be used for most facilities. The final strategy must take into account the limits of Missouri’s budget.

2. Environmental Outcomes

The State of Missouri: MDNR assessed 21.8% of the State’s rivers and streams for aquatic life use support, with 47% not impaired; 42% of rivers and streams for fish consumption, with 1% impaired; and 21.8% for swimming with 0.2% impaired. MDNR assessed 100% of lakes for aquatic life with 0.0% impaired; 100% for fish consumption, with less than 1% impaired; and 100% for swimming, with less than 1% impaired, which is better than the national average. The MDNR relies on a statewide monitoring plan and has a strong volunteer monitoring program.

3. Water Quality Standards

The State of Missouri: The State of Missouri’s water program was recently reorganized. Part of this effort involved reassigning the permitting section chief to the Water Quality Monitoring and Assessment Section. Region 7 is hopeful that this will result in more effective coordination between the permitting and water assessment activities. The State of Missouri’s waters are divided into classified waters and unclassified waters. Beneficial uses are designated only for classified waters. General criteria apply to all waters of the State and specific criteria apply to classified waters in accordance with designated uses. No use attainability analysis (UAA) has been submitted in support of designated uses; however, Missouri has developed a protocol for UAAs on recreational uses. Several UAAs are expected to be completed in calendar year 2005 through a grant and contract awarded to consultants. Some standards are difficult to implement because of a lack of guidance on rule implementation. Missouri has improved its rule implementation by recently developing guidance on the listing of impaired water bodies under section 303(d) of the Clean Water Act and water classification in addition to the UAA Protocol. Missouri has begun the development of implementation guidance on antidegradation (MDNR does not currently have an antidegradation policy) as well as new criteria for nutrients, aquatic life uses and sediment, and site-specific numeric standards for dissolved oxygen. Missouri could improve its standards by developing numeric translators for the State’s general criteria.

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The State of Missouri’s most recent revisions of its water quality standards were submitted in 1994 and 1996. EPA regarded the collective revisions as a triennial review and issued decisions on these revisions in September 2000. In March 2001, the State established a three-phased approach to its next triennial review. Missouri has progressed with the drafting of rule revisions to address Phase I of the rulemaking effort. Because of new statutory provisions relating to rulemaking, Missouri has postponed filing the draft rule until the new administrative requirements are met.

Missouri’s rulemaking will include 23 revisions to the State’s water quality standards. Among the revisions expected in 2005 is a designation of Whole Body Contact Recreation to all classified waters. The rules will also include a change to the State of Missouri’s bacteriological ambient water quality standards. The State is expected to adopt the current standard for fecal coliform bacteria with an E. coli standard that is consistent with EPA’s 1986 recommendations. The State of Missouri plans to develop nutrient criteria for lakes by 2006. Stream nutrient criteria are scheduled to be developed by 2008.

In October 2003 the Missouri Coalition for the Environment brought an action against EPA for declaratory and injunctive relief for the alleged failure to ensure that MDNR water quality standards provide the State of Missouri’s residents with clean and safe water. This lawsuit was settled on December 27, 2004. The outcome will have direct implications for Missouri’s water quality standards program, many of which are addressed by Missouri’s proposed Phase I water quality standards revisions.

4. Total Maximum Daily Loads

The State of Missouri: The MDNR performs a water quality review on all individual permit applications. A water quality review of a major individual permit (and certain larger minor individual permits) is documented in a water quality review sheet, which is published with a permit when it is posted for public comment. Applications for coverage under a general permit are addressed by a water quality review performed when the terms and conditions of the general permit were determined. The water quality review done at the time of issuance of the general permit is documented in a fact sheet that is published when the general permit is posted for public comment. For Missouri’s wasteload allocations, all permits contain reopener clauses that trigger a revision to the permit when TMDLs are completed. The TMDLs are assigned, or allocated, to the discharging sources through various means. For point sources, the portion of the TMDL allocated to each source is back-calculated as limits on the outfalls using standard modeling approaches. Consideration is given to the maximum design production (or load) capacity of each facility. The portion of the TMDL allocated to each facility is identified in a water quality review sheet that accompanies each permit. Permits are then modified to reflect their new effluent limits and require the monitoring necessary to determine whether the limits are sufficiently protective.

When MDNR reissues permits to facilities discharging to waterways listed as impaired and for which there is no approved TMDL, MDNR writes water quality-based permits that implement State standards and criteria as required by the 10 CSR 20-7 water quality rules.

The MDNR has approved 37 TMDLs; the State continues to meet its commitment to scheduled TMDL development under the February 2001 TMDL consent decree. The decree allows the State to use delisting to count toward TMDL requirements. In 2003, 36 TMDLs were required. To meet this requirement, the State of Missouri delisted 26 waters, completed 3 TMDLs during FY 2003 and an

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additional 8 TMDLs during early FY 2004, for a total of 37 TMDLs either completed or negated through delisting.

5. Safe Drinking Water Act

The State of Missouri: The Drinking Water and NPDES programs are linked through the State’s water quality standards. “Drinking Water Supply” is, for some Missouri waters, a designated beneficial use. Standards, wasteload allocations, and water quality-based effluent limits are developed to protect this use.

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Section V. Other Program Highlights

The State of Missouri: MDNR has been very effective in using information technology to enhance its work process. In house, MDNR is using computer tracking and computer templates to create greater efficiency in permit development. Public notices and many other documents are available on the MDNR web site, giving much greater public access to all parts of NPDES permitting, TMDLs, and other issues of concern to the general public.

The State of Missouri has been a national leader in the use of general permits to cover sets of dischargers. The library of general permits used by MDNR is one of the most extensive in the nation.

MDNR’s volunteer monitoring network, the Stream Teams, has been a very effective means of gathering basic data on Missouri’s streams. The Stream Teams collect data year-round, and often stage annual cleanups in the urban waterways of Missouri. These teams involve many members of the public, as well as the scientific community and academia, other State environmental agencies, environmental consultants, and special interest groups, and all of them are very helpful as stakeholders for many of the water quality efforts.

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Profile Section

GPRA Goal Nat. Avg.

State Activities

EPA Activities

1 # major facilities (6,690 total) I.1 n/a 145 0

2 # minor facilities covered by individual permits (42,057 total) I.1 n/a 2,879 0

3 # minor facilities covered by non-storm water general permits (39,183 total) I.1 n/a 2,064 0

4 # priority permits (TBD) I.6 -- --

5 # pipes at facilities covered by individual permits (142,761 total) I.7 n/a 8,969 --

6 # industrial facilities covered by individual permits (32,505 total) I.1 n/a 2,201 0

7 # POTWs covered by individual permits (15,197 total) I.1 n/a 807 0

8 # pretreatment programs (1,482 total) II.2 n/a 42 --

9 # Significant Industrial Users (SIUs) discharging to pretreatment programs (22,158 total)

II.2 n/a 566 --

10 # Combined Sewer Overflow (CSO) permittees (831 total) II.5 n/a 8 --

11 # CAFOs (current and est. future) (17,672 total) II.3 n/a 443 --

12 # biosolids facilities (TBD '05) II.6 -- --

13 State or Region assessment of State NPDES program (none (N)/assessment (A)/profile (P))

I.1 50 states 2004

n/a A, P P

14 % pipes at facilities covered by individual permits w/ lat/long in PCS I.7 46.3% 79.0% --

15 State CAFO legal authority expected (mo/yr) II.3 2005 n/a 11/04 n/a

16 # Withdrawal petitions/legal challenges (22 total) I.4 n/a 0 n/a

17 DMR data entry rate I.7 95% 82% --

18 # permit applications pending (1,011 total) I.6 n/a 159 --

19 % major facilities covered by current permits I.6 90% 83.7% 66.9% n/a

20 % minor facilities covered by current individual or non-storm water general permits

I.6 90% 12/04 87.0% 68.4% n/a

21 # major facilities w/permits expired >10 yrs. (56 total) I.6 n/a 1 0

22 % priority permits issued as scheduled (TBD '05) I.6

95% 2005 -- --

23 % pretreatment programs inspected/audited during 5 yr. inspection period

II.2 85.3% 50.0% --

24 % SIUs w/control mechanisms II.2 99.2% 98.4% --

25 % of CSO permittees with long-term control plans developed or required II.5

75% 2008 82.2% 75.0% --

26 % CAFOs covered by NPDES permits II.3 35% 98% --

27 % biosolids facilities that have satisfied part 503 requirements (TBD '05) II.6 -- --

28 # Phase I storm water permits issued but not current (76 total) II.4 n/a 0 n/a

29 # Phase I storm water permits not yet issued (5 total) II.4 n/a 2 0

30 Phase II storm water small MS4 permits current (Y/N/D (draft)) (35 States)

II.4 100% states 2008

n/a Y n/a

31 Phase II storm water construction permit current (Y/N/D (draft)) (49 States) II.4

100% states 2008

n/a Y n/a

32 % major facilities inspected III.3 71% 34% 6%

33 (inspections at minors) / (total inspections at majors and minors) III.3 76% 94% 66%

34 % major facilities in significant non-compliance (SNC) III.1 20% 12% --

35 % SNCs addressed by formal enforcement action (FEA) III.1 14% 0% --

36 % SNCs returned to compliance w/o FEA III.1 70% 90% --

37 # FEAs at major facilities (666 total) III.1 n/a 0 2

38 # FEAs at minor facilities (1,660 total) III.1 n/a 5 34

NPDES Progress

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Pro

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Adm

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Pro

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National Data Sources Additional Data State

Activities EPA

Activities

439

5/05

83%

0

NPDES Management Report, Winter 2005 Missouri

Explanation of Column Headers:

Profile Section: For each measure, this column lists the section of the profile where the program area (including any additional data for the measure) is discussed.

National Data Sources: The information in these two columns is drawn from two types of sources:

(1) EPA-managed databases of record for the national water program, such as PCS, the National Assessment Database, and the National TMDL Tracking System. NPDES authorities are responsible for populating PCS with required data elements and for assuring the quality of the data. EPA is working to phase in full use of NAD and NTTS as national databases.

(2) Other tracking information maintained by EPA Headquarters for program areas such as CAFOs, CSOs, and storm water.

The definitions document accompanying this Management Report provides a detailed definition of each data element in the National Data Sources columns.

Additional Data: These columns provide additional data in cases where information from other data sources differs from information in the National Data Sources column for reasons such as different timing of the data "snapshot." Additional data should generally adhere to the same narrative definitions as data in the National Data Sources, and should be derived using similar processes and criteria. Our goal is to work with the States on these discrepancies to ensure consistent and accurate reporting. A State contact is available who can respond to queries. The profiles discuss each additional data element.

State Activities: Information in these columns reflects activities conducted by the State program. (Shaded cells in these columns indicate that the work may not be entirely the State's responsibility, but a breakdown of the data into EPA and State responsibilities is unavailable.)

EPA Activities: Information in these columns reflects activities conducted by the EPA Region within the State.

http://www.epa.gov/npdes/pubs/per_definitions.pdf

NPDES Management Report, Winter 2005 Missouri

Profile Section

GPRA Goal Nat. Avg.

State Activities

EPA Activities

State Activities

EPA Activities

Water Quality Progress 39 River/stream miles

(3,419,857 total) IV.2 n/a 101,900 n/a

40 Lake acres (27,775,301 total) IV.2 n/a 220,912 n/a

41 Total # TMDLs in docket at end of FY 2003 (52,795 total) IV.4 n/a 216 --

42 # TMDLs committed to in FY 2003 management agreement (2,435 total) IV.4 n/a 36 0

43 # Watersheds (2,341 total) IV.2 n/a -- --

44 On-time Water Quality Standards (WQS) triennial review completed (42 States) IV.3 n/a N n/a

45 # WQS submissions that have not been fully acted on after 90 days (32 total) IV.3

<25% submis-sions

n/a n/a 0

46 State is implementing a comprehensive monitoring strategy (Y/N) (TBD) IV.1

all states 2005

-- -- --

47 % river/stream miles assessed for recreation IV.2 13.8% 21.8% n/a

48 % river/stream miles assessed for aquatic life IV.2 22.0% 21.8% n/a

49 % lake acres assessed for recreation IV.2 49.4% 100.0% n/a

50 % lake acres assessed for aquatic life IV.2 48.5% 100.0% n/a

51 # outstanding WQS disapprovals (23 total) IV.3 n/a 1 n/a

52 WQS for E. coli or enterococci for coastal recreational waters (12 States)

IV.3 35 states 2008

n/a n/a n/a

53 WQS for nutrients or Nutrient Criteria Plan in place (13 States)

IV.3 25 states 2008

n/a N n/a

54 Cumulative # TMDLs completed through FY 2003 (10,807 total) IV.4 n/a 37 --

55 # TMDLs completed in FY 2003 (2,929 total) IV.4 n/a 3 0

56 # TMDLs completed through FY 2003 that include at least one point source WLA (5,036 total)

IV.4 n/a 36 --

57 % Assessed river/stream miles impaired for swimming in 2000 IV.2 -- 0.2% n/a

58 % Assessed lake acres impaired for swimming in 2000 IV.2 -- 0.0% n/a

59

# Watersheds in which at least 20% of the water segments have been assessed and, of those assessed, 80% or more are meeting WQS (440 total)

IV.2 600 2008 n/a -- --

Uni

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ater

Qua

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Adm

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ater

Qua

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Impl

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nviro

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tal

Out

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es

Additional DataNational Data Sources Explanation of Column Headers:

Profile Section: For each measure, this column lists the section of the profile where the program area (including any additional data for the measure) is discussed.

National Data Sources: The information in these two columns is drawn from two types of sources:

(1) EPA-managed databases of record for the national water program, such as PCS, the National Assessment Database, and the National TMDL Tracking System. NPDES authorities are responsible for populating PCS with required data elements and for assuring the quality of the data. EPA is working to phase in full use of NAD and NTTS as national databases.

(2) Other tracking information maintained by EPA Headquarters for program areas such as CAFOs, CSOs, and storm water.

The definitions document accompanying this Management Report provides a detailed definition of each data element in the National Data Sources columns.

Additional Data: These columns provide additional data in cases where information from other data sources differs from information in the National Data Sources column for reasons such as different timing of the data "snapshot." Additional data should generally adhere to the same narrative definitions as data in the National Data Sources, and should be derived using similar processes and criteria. Our goal is to work with the States on these discrepancies to ensure consistent and accurate reporting. A State contact is available who can respond to queries. The profiles discuss each additional data element.

State Activities: Information in these columns reflects activities conducted by the State program. (Shaded cells in these columns indicate that the work may not be entirely the State's responsibility, but a breakdown of the data into EPA and State responsibilities is unavailable.)

EPA Activities: Information in these columns reflects activities conducted by the EPA Region within the State.

http://www.epa.gov/npdes/pubs/per_definitions.pdf

per npdes profile: missouri · commission (a board appointed by missouri’s governor). permitting...

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